Privacy Policy

PRIVACY POLICY

Welcome to our website, which was created and edited by ROBERTO COIN S.p.A. (hereafter referred to simply as “Roberto Coin”), with registered office at viale Trieste no. 13, in Vicenza, Italy, registered at the company registry of Vicenza under number 02193150246, REA Register No. 26090 company’s capital EUR 1.500.000,00 (one million five hundred thousand/00), fully paid-up capital.The present document constitutes the Privacy Policy of the Roberto Coin website, it demonstrates our commitment to the safety and protection of personal data of visitors to our site, pursuant to section 13 of Italian Legislative Decree No. 196 of 30 June 2003, Personal Data Protection Code (hereafter referred to as Privacy Code).

The reason for this noticeIn the following pages, Roberto Coin describes the managerial procedure for processing Personal Data of visitors to the site. It consists of a statement pursuant to section 13 of Italian Legislative Decree No. 196 of 30 June 2003, Personal Data Protection Code for visitors interacting with web services directly provided by Roberto Coin for the protection of personal data, accessible online at the following address: http://www.robertocoin.com, home page of the official Roberto Coin website. The statement applies only to the Roberto Coin site and not to any other sites visited by users through links. The statement is also modeled on Recommendation 2/2001 that the European authorities for the Protection of Personal Data, reunited in the Working Party established by article 29 of Directive No. 95/46/CE adopted on 17th May, 2001, in order to characterize some minimum requirements for collecting personal data on-line and particularly, the modalities, times and types of information that the Controller of data processing must provide visitors to its site when they connect to web pages, independently of the purpose of the connection. Therefore, we kindly invite you to read our Privacy Policy, stated hereafter.The founding principles of the Roberto Coin Privacy Policy, in observance of the Personal Data Protection norms, are as follows:

1) Principle of purpose of data processing or minimizing: at the time of personal data collection visitors to the site are informed of the purpose of data processing. Possible changes in data processing that differ from those declared at the time of initial data collection only take place after a new statement has been disclosed to visitors of the site and after their consent has been requested, in conformity to the requirements of the Privacy Code.Personal Data will only be used if necessary and to the purpose determined before its acquisition.

2) Principle of necessity: the use of personal data is limited to cases of absolute necessity in regard to the principle of purpose of data processing and linked to the principle of transparency.

3) Principle of statement: at the time of data disclosure visitors to the site are provided the specific statement, as requested by article 13 of the Privacy Code, which you can read hereafter.

4) Safety principle: appropriate safety measures will be put in place to protect against the loss or disclosure of data to unauthorized third parties during acquisition, processing and conservation of personal data.

5) Transparency principle: personal data is collected and processed according to the principles shown in the Privacy Policy adopted by Roberto Coin, expressed herein. At the time of data collection a brief and complete statement, in conformity with article 13 of the Privacy Code, is provided to the visitors of the site.

CONTROLLER OF DATA PROCESSINGFollowing a visit to this site personal data processing related to identified or identifiable persons can take place. The Data Treatment Controller is Roberto Coin S.p.A., with registered office at via Trieste no. 13, in Vicenza, Italy, e-mail: [email protected]

KINDS OF DATA PROCESSED

Surfing data It is useful to know, that the electronic systems and software procedures in control of the functioning of this site, acquire some personal data during the course of their normal running, the transmission of which is implicit to the use of Internet communication protocols. Such data, although not collected to be associated to identified data subjects, could because of its character, lead to identification of data subjects, through elaborations and associations with data held by third parties. IP addresses or domain names of computers used by visitors to the site, URI (Uniform Resource Identifier) annotated addresses of the requested resources, time of request, used method for submitting request to server, dimension of file obtained as response, the numeric code indicating response status by the server (successfully submitted, error, etc.) and other parameters regarding visitors’ operating system and IP environment, fall under this category. Such data is used by Roberto Coin with the sole purpose of obtaining anonymous statistical information about use of the site and to monitor its correct functioning.This data could be used to ascertain responsibility in case of hypothetical IT crimes which damage the site.

CookiesNo Cookies are used for the transmission of personal information, nor are any kind of persistent c.d. cookies used or user tracking systems or session cookies. Therefore, no user personal data is intentionally acquired by the site.

Data voluntarily provided by user Data optionally, explicitly and voluntarily sent by e-mail to the addresses indicated in this site, entails subsequent acquisition of sender’s address, needed to respond to requests, as well as of other personal data included in the message.Special brief statements will be continuously cited and displayed on the site’s pages for special on-demand services. It is hereby specified, that Roberto Coin does not request disclosure of any sensitive data, to provide services on its site. Therefore, visitors to the site are kindly requested to abstain from disclosing any sensitive data in their communications sent to the addresses present in the site.We herewith remind you, that sensitive data are those that can reveal racial and ethnic origins, religious, philosophical or other kind of beliefs, political opinions, party or union affiliation, or affiliation with associations or organizations of religious, philosophical, political or union nature, as well as personal data that can reveal state of health and sexual life.Roberto Coin informs that, in accordance with art. 26 of the Privacy Code, sensitive data can be processed only with the data subject’s written consent and the Guarantor’s prior authorization.Therefore, Roberto Coin will not process sensitive data and will proceed to eliminate such data that may be communicated spontaneously, except where specified as follows.Regarding sent Curricula, Roberto Coin reminds that, in case sensitive data should be included, the general authorization by the Guarantor exists to process sensitive data related to work relations, but written authorization by the subject will nonetheless be necessary.Roberto Coin will proceed to delete curricula containing sensitive data from its archives, in case written authorization for processing of sensitive data by the data subject is not received within 30 days of submitting the curriculum.For such purpose, the data subject must display the specific statement of the “Curriculum”/”Careers” section, enclosing the following footnote, stating: “ I herewith consent to the processing of my data – (signature)” and send the written consent to Roberto Coin S.p.A, viale Trieste 13, 36100 Vicenza, Italy, by registered mail with return receipt. No data processing will take place between the date the curriculum containing sensitive data is sent and the date the written consent is received, or rather during the 30 days after submitting the curriculum, however, the usual safety measures shall be applied for the protection of the received data.

OPTIONALITY OF DATA DISCLOSUREBesides what has been established for surfing data, users are free to disclose personal data, shown in contacts with Roberto Coin, to request mailing of informational material or of other communications. Failure to disclose such data will result in the impossibility to fulfill such requests.Users are also free to disclose personal data requested in the registration forms for services. Some data may be indicated as mandatory: such data is necessary for the fulfillment of the requested service. Detailed information is given in those sections in which it is compulsory to fill in some fields in order to obtain the service required.

PURPOSE OF DATA PROCESSINGBesides what has been established with regard to surfing data, Roberto Coin, will process data provided by visitors with the sole purpose of fulfilling requests received at the physical and electronic addresses present on the site , under the “Contacts” section, and with the purpose of personnel search and selection, under the sections “Carrers” and “Curriculum”. With the exception of the statements pursuant to art. 13 of the Privacy Code in the specific sections of Roberto Coin’s website, data is to be disclosed only when requested, regarding the purpose of processing, besides the modality, the mandatory or voluntary character of providing data, to the consequences of failing to provide data to the data controller and data processors, to the subjects or categories of subjects whose personal data can be communicated and the area of data disclosure, to the rights pursuant to art. 7 of the Privacy Code.

PLACE AND PURPOSE OF DATA PROCESSINGData processing related to the web services of this site take place at the abovementioned branch of Roberto Coin and data is processed by specially assigned Roberto Coin staff, or by people in charge of occasional maintenance operations. Roberto Coin uses the personal data provided by visitors to its site with requests for information and/or for informational material with the sole purpose of providing the requested service.Categories of third parties to whom personal data may be communicated Roberto Coin, in order to guarantee that all the activities necessary and/or useful for performing the services requested, where absolutely unavoidable, may communicate the personal information provided by the user to third parties located in Italy and /or abroad, to whom Roberto Coin may entrust some activities (for example, shipping services). Roberto Coin might communicate the personal data acquired to third parties in order to comply with legal obligations, to fulfil orders from public authorities empowered to do so, or even to exercise and defend a right in court. In no other situations, shall the information deriving from the web service be communicated or diffused. The personal information is processed both manually and electronically for the time strictly necessary to complete the procedures it was collected for and, in any case, for no more than 30 days.

SAFETY MEASURESSpecific safety measures are applied to prevent the loss of data, their illegal or incorrect use and access to unauthorized persons. Such safety measures meet the minimum requirements indicated by the legislator (Disciplinary Technician for matters of minimum safety measures pursuant to articles 33 and following of Legislative Decree 196/03).Roberto Coin points out that the efficient functioning of safety measures is constantly being checked.

USERS’ RIGHTS Data subjects have the right at any time to obtain confirmation as to whether or not personal data concerning them exists, to know the source and origin of personal data; to request updating, integration or rectification of data, according to art. 7 of Legislative Decree No. 196/2003. Pursuant to the same article, users also have the right to request deletion of their data, transformation of the same into anonymous form or blocking of data that has been processed unlawfully, as well as the right to object, for legitimate reasons, to the processing of such data.Upon user request, ROBERTO COIN will provide modification and integration of personal data, or rather deletion of the pertaining personal information from its database. Requests are to be addressed to ROBERTO COIN with the following modality: - by e-mail to [email protected]; by registered mail with return receipt to: Roberto Coin S.p.A, viale Trieste no. 13, 36100 Vicenza, Italy.Inquiries about Protection of Personal Data can be addressed to Roberto Coin S.p.A, viale Trieste no. 13, 36100 Vicenza, Italy, and to [email protected].* * * The present document , published at http://www.robertocoin.com constitutes the “Privacy Policy” of this site and will be subject to updates.Following is the complete text of articles 7 and 13 of the Privacy Code:

Art. 7 -(Right to Access Personal Data and Other Rights) 1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form. 2. A data subject shall have the right to be informed a) of the source of the personal data; b) of the purposes and methods of the processing; c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2); e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing. 3. A data subject shall have the right to obtain a) updating, rectification or, where interested therein, integration of the data; b) deletion, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disclosed, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. 4. A data subject shall have the right to object, in whole or in part, a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication survey

Art. 13 - (Information to Data Subjects) 1. The data subject as well as any entity from whom or which personal data are collected shall be preliminarily informed, either orally or in writing, as to: a) the purposes and modalities of the processing for which the data are intended; b) the compulsory or voluntary nature of providing the requested data; c) the consequences if (s)he fails to reply; d)the entities or categories of entity to whom or which the data may be communicated or who/which may get to know the data in their capacity as data processors or persons in charge of the processing, and the purpose of disclosure of said data;e) the rights as per Art. 7;f) the identification data concerning the data controller and, where designated, the data controller’s representative in the State’s territory pursuant to Art. 5 and the data processor. If several data processors have been designated by the data controller, at least one among them shall be referred to and either the site on the communications network or the mechanisms for easily accessing the updated list of data processors shall be specified. If a data processor has been designated to provide answers to data subjects in case the rights as per Art. 7 are exercised; such data processor shall be referred to.2. The information as per paragraph 1 shall also contain the items referred to in specific provisions of this Code and may fail to include certain items if the latter are already known to the entity providing the data or their knowledge may specifically impair supervisory or control activities carried out by public bodies for purposes related to defence or State security, or else for the prevention, suppression or detection of offences.3. The Guarantor may issue a provision to set out simplified information arrangements as regards, in particular, telephone services providing assistance and information to the public.4. Whenever personal data is not collected from the subject, information as per paragraph 1, also including the categories of processed data, shall be provided to the data subject at the time of recording such data or, if its communication is envisaged, no later than when the data is first communicated.5. Paragraph 4 shall not applya) if the data is processed in compliance with an obligation imposed by a law, regulations or Community legislation.b) if data is processed either for carrying out investigations by defense counsel as per Act no. 397 of 07.12.2000 or to establish or defend a legal claim, provided that data is processed exclusively for said purposes and for no longer than is necessary for that purpose;c) if the provision of information to the data subject involves an effort that is declared by the Guarantor to be manifestly disproportionate compared with the right to be protected, in which case the Guarantor shall lay down suitable measures, if any, or if it proves impossible in the opinion of the Guarantor.

Legal Notices

Limits to the use of the Roberto Coin site

The website es.robertocoin.com (hereafter referred to as the ""site"") is the official company site of Roberto Coin S.p.A. (hereafter referred to simply as ""Roberto Coin"") with registered office at Vicenza, viale Trieste no. 13, registered at the company registry of Vicenza under number 02193150246, REA 26090 company's capital Euro 1.500.000,00 (one million five hundred thousand/00), fully paid-up capital.Roberto Coin kindly invites you to carefully read the present Legal Notes before proceeding to visit the site, pointing out that use of this site requires full and automatic acceptance of the legal conditions and information specified hereafter. Therefore, proceeding to consult the site will entail full acceptance of the conditions specified hereafter. In case of failing to accept the abovementioned conditions, you will not be authorized to proceed visiting the site.

Purpose and content of the website

All contents and information included on the site are intended to provide information about Roberto Coin and in general about the ""Roberto Coin"" brand as well as about all other Roberto Coin products and services.Roberto Coin reserves the right to modify, add or eliminate contents of the site at any time, for any reason and in any way, without previously needing to notify anyone. Modifications shall be effective from the date of publication on the site. Roberto Coin shall not be responsible in any way for the possible consequences of the implemented modifications.

Intellectual property

The Roberto Coin site, inclusive of texts, images, photographs, advertising campaigns, press releases, audio and video tracks, design, graphics, wording of the site, used logos and symbols, names and denominations of products and services, designs and models, are legally protected. All rights on the contents are reserved under the current law.All contents of the site cannot be modified or used in any way and in particular they cannot be copied, reproduced, transferred, published or distributed totally or partially in any way, without the previous written consent of Roberto Coin ? except for being saved onto your own personal computer and printing excerpts of the pages contained therein, exclusively for your own personal use, for private and non-commercial purposes, as long as they don't bring about any modifications to the site.The brands, logos and any other distinctive signs present on the site are Roberto Coin's property and cannot be used in any way without previous written consent of Roberto Coin. The site, the graphics, the texts are subject to Copyright by the owner of the brands (all rights reserved).The names ""Roberto Coin"" and ""Coin Roberto"" cannot be used as internet address for other sites or as part of such addresses; they cannot be part of html codes (or of other such languages) of the diverse pages of other sites. Furthermore the creation of hyperlinks to the present site by third parties is forbidden, unless previously authorized in writing.Unlawful use of the site's contents can constitute a violation of the current copyright law, of commercial brands, on the right of advertising, on the respect of privacy and on the right of communication and shall be punished before the civil and criminal authorities having jurisdiction.

E-mail

The site offers the possibility to send e-mail messages to Roberto Coin, to companies of the group, as well as to the Roberto Coin dealer in Great Britain. The sending of such messages is at the sender's own risk.Legal communications sent by e-mail shall not be considered effective. For such purpose, we point out, that any answer or failed answer in respect to e-mail messages sent to the web addresses present in the site cannot be interpreted as legally effective consent or denial.

Responsabilities

Roberto Coin will take care to verify the correctness of data contained in the site, so that it is complete and updated, without this meaning explicit or implicit assumption of any responsibility. The above specified is also valid with regard to the information on quality, availability or eligibility for specific products or services displayed in the site.Roberto Coin does not guarantee access without difficulty, or uninterrupted access to this site.Roberto Coin is not in any way responsible for direct, indirect, casual or consequentially incurred damages arising from use of the site, or rather for the impossibility or difficulty of using the present site. Such exemption of liability is also effective for damages caused by viruses or other damaging programmes or rather caused by visitors to the site to the users' computer or their software or data.

Sending of information to Roberto Coin

Except for what is foreseen in the Privacy Policy document of the site that Roberto Coin kindly invites you to read before proceeding to consult the site, all unrequested communications and information (including, e.g. questions, suggestions, requests and any other such data) sent to Roberto Coin by visitors to the site by e-mail or in other form, shall be held as non-confidential. Therefore, Roberto Coin shall not be liable in any way with respect to the contents of such communications of information and shall be able to reproduce them, use them, modify them, sell them, publish them, by themselves or integrating them into other products of any form, technology or means used, as well as to make use of them for development, production and commercialization of products that use such information.